Although many Americans are extremely patriotic, more and more Americans are playing ”The Expatriation Games”

<p>December 14, 2021 - Participants Include:</p> <p> </p> <p>Olivier Wagner CPA - <a href='http://www.twitter.com/1040abroad'>@1040Abroad</a></p> <p>John Richardson - <a href='http://www.twitter.com/expatriationlaw'>@Expatriationlaw</a></p> <p> </p> <p>The Expatriation Games - A Discussion with Oliver Wagner</p> <p>This podcast features a practical and focussed discussion about some of the key issues in relinquishing US citizenship. Olivier has <a href='https://www.youtube.com/watch?v=hm_yyJJ9luY'>posted this podcast on his youtube channel</a>.</p> <p> </p> <p> These issues include:</p> <p> </p> <p>There are two kinds of US citizenship:</p> <p>1. US Citizenship for immigration/nationality purposes:</p> <p>- relinquished on the date of the relinquishing act</p> <p> </p> <p>2. US Citizenship for tax purposes:</p> <p>- after June 3, 2004 relinquished on the date that notice is given to the US government</p> <p>- prior to June 3, 2004 relinquished on the date of the expatriating act</p> <p>___________________________________________</p> <p>Covered expatriate status - tax compliance is necessary:</p> <p>- one (but the not the only one) of the necessary conditions to avoid "covered expatriate" status is a certification of five years of tax compliance (in the five years prior to the year of the appointment at the Consulate)</p> <p>- obviously this means that a defensible level of tax compliance is required </p> <p> </p> <p>____________________________________________</p> <p>Significance of Form 8854:</p> <p>After listening to this podcast I think this issue deserves further clarification as follows:</p> <p>- Since June 16, 2008 it is NOT necessary to file Form 8854 in order to sever tax residency from the USA. One ceases to be a US tax resident from the date of renunciation. This means that from that point on one is  treated as a nonresident alien. But, note that renunciation does not cure/end past tax obligations.</p> <p>- But the tax certification of five years compliance is required to be do